Frame Index Co., Ltd. recognizes the importance of protecting your personal data. This Privacy Policy explains our practices regarding the collection, use, or disclosure of personal data, as well as the various rights of data subjects, in accordance with personal data protection laws.

Collection of Personal Data

We will collect personal data received directly from you through the following channels:

• Membership registration
• Telephone
• Email
• Facebook Login
• Google Login

Types of Personal Data Collected

Personal Information such as first name, last name, age, date of birth, nationality, national ID number, passport number, etc.

Contact Information such as address, telephone number, email, etc.

Account Information such as user account, usage history, etc.

Proof of Identity such as a copy of the national ID card, a copy of the passport, etc.

Transaction and Financial Information such as purchase history, credit card details, bank accounts, etc.

Technical Information such as IP address, Cookie ID, website usage history (Activity Log), etc.

Other Information such as images, moving images, and any other information considered personal data under personal data protection laws.

Minors

If you are under 20 years of age or have legal capacity limitations, we may collect, use, or disclose your personal data. We may require consent from your parents or guardians or as permitted by law. If we become aware that personal data has been collected from a minor without parental or guardian consent, we will proceed to delete that information from our servers.

Methods of Storing Personal Data

We will maintain your personal data in both document and electronic formats.

We store your personal data as follows:

• Overseas server providers

Processing of Personal Data

We will collect, use, or disclose your personal data for the following purposes:

• To create and manage user accounts
• To deliver products or services
• To improve products, services, or user experience
• For internal company management
• For marketing and sales promotion
• For after-sales service
• To collect feedback
• To process payments for products or services
• To comply with Terms and Conditions
• To comply with laws and government regulations

Disclosure of Personal Data

We may disclose your personal data to others with your consent or as permitted by law, as follows:

Internal Organizational Management

We may disclose your personal data within the company as necessary to improve and develop our products or services. We may aggregate internal information for various products or services under this policy for your benefit and the benefit of others.

Service Providers

We may disclose some of your personal data to our service providers as necessary to perform operations in various areas such as payments, marketing, and product or service development. These service providers have their own privacy policies.

Business Partners

We may disclose certain information to business partners to contact and coordinate the provision of products or services, and to provide necessary information regarding the availability of products or services.

Law Enforcement

In the event of a request by law or a government agency, we will disclose your personal data as necessary to government agencies such as courts, government offices, etc.

Cross-Border Transfer of Personal Data

We may disclose or transfer your personal data to individuals, organizations, or servers located abroad. We will take various measures to ensure that the transfer of your personal data to the destination country has adequate personal data protection standards, or in other cases as prescribed by law.

Retention Period of Personal Data

We will retain your personal data for the period necessary while you are a customer or have a relationship with us, or for the duration necessary to achieve the purposes related to this policy. It may be necessary to retain it thereafter if required by law. We will delete, destroy, or anonymize your data when it is no longer necessary or when the said period ends.

Rights of the Data Subject

Under personal data protection laws, you have the following rights:

Right to withdraw consent If you have given consent for us to collect, use, or disclose your personal data, whether given before or after the personal data protection law came into effect, you have the right to withdraw that consent at any time.

Right to access You have the right to request access to your personal data under our responsibility and to request a copy of such data, including requesting disclosure of how we obtained your personal data.

Right to data portability You have the right to obtain your personal data in a format that is readable or usable by automatic tools or devices and can be used or disclosed by automated means. You also have the right to request us to send or transfer personal data in such format to another data controller when possible by automated means, and to receive personal data that we send or transfer directly to another data controller, unless it cannot be done due to technical reasons.

Right to object You have the right to object to the collection, use, or disclosure of your personal data at any time if it is done for necessary operations under our legitimate interests or those of another person or legal entity, within a scope you can reasonably expect, or to perform a task for the public interest.

Right to erasure/destruction You have the right to request the deletion or destruction of your personal data or to make it anonymized if you believe your personal data was collected, used, or disclosed unlawfully under relevant laws, or if you consider that we no longer need to retain it for the purposes stated in this policy, or when you have exercised your right to withdraw consent or object as mentioned above.

Right to restriction of processing You have the right to request a temporary suspension of the use of your personal data while we are investigating your request to rectify personal data or your objection, or in any other case where we no longer need to delete or destroy your personal data according to relevant laws but you request suspension of use instead.

Right to rectification You have the right to request that your personal data be corrected, kept up-to-date, complete, and not misleading.

Right to lodge a complaint You have the right to lodge a complaint with the relevant legal authorities if you believe that the collection, use, or disclosure of your personal data violates or fails to comply with relevant laws.

You can exercise your rights as a data subject above by contacting our Data Protection Officer as detailed at the end of this policy. We will notify you of the result within 30 days from the date we receive your request, according to the forms or methods we prescribe. If we reject the request, we will inform you of the reason through various channels such as SMS, email, telephone, or letter.

Advertising and Marketing

For the benefit of receiving our products or services, we use your information to analyze and improve products or services and conduct marketing through Google, Facebook, pixel tracking codes, and others. We use such information to tailor products or services to you.

Our website may display advertisements from third parties to facilitate our services, such as Google AdSense or BuySellAds. These third parties may access your personal data only to perform these tasks and are obligated not to disclose or use it for any other purpose.

We may send information or newsletters to your email to offer things of interest to you. If you no longer wish to receive communications from us via email, you can click “Unsubscribe” in the email link or contact us via our email.

Tracking Technology (Cookies)

To make your user experience more complete and efficient, we use cookies or similar technologies to improve access to products or services, provide appropriate advertising, and track your usage. We use cookies to identify and track website users and access to our website. If you do not want cookies on your computer, you can set your browser to refuse cookies before using our website.

Personal Data Security

We will maintain the security of your personal data according to the principles of confidentiality, integrity, and availability to prevent loss, unauthorized access, use, alteration, modification, or disclosure. In addition, we will provide personal data security measures covering administrative safeguards, technical safeguards, and physical safeguards regarding access control.

Notification of Personal Data Breach

In the event of a personal data breach, we will notify the Office of the Personal Data Protection Commission without delay within 72 hours of becoming aware of the incident, where feasible. If the breach poses a high risk to your rights and freedoms, we will notify you of the breach along with remedial guidelines without delay through various channels such as the website, SMS, email, telephone, or letter.

Amendments to the Privacy Policy

We may amend this policy from time to time. You can find the revised terms and conditions of this policy through our website.

This policy was last updated and is effective as of June 01, 2022.

Privacy Policies of Other Websites

This Privacy Policy applies only to the offering of products, services, and usage on the website for our customers. If you visit other websites, even through our website channels, the protection of personal data will be subject to the privacy policy of that website, with which we are not affiliated.

Contact Details

If you have any questions regarding this Privacy Policy or wish to exercise your rights, you can contact us or our Data Protection Officer as follows:

Data Controller

Frame Index Co., Ltd.

14/116 Moo 7, Liang Muang Samakkhi Rd., Bang Talat, Pak Kret, Nonthaburi 11120

Email: zhou.jirawat@gmail.com

Website: https://xn--12c4cd4ab2dwe.com/

Telephone: 084-360-1168

Data Protection Officer (DPO Officer)

Jirawat Zhou

14/116 Moo 7, Liang Muang Samakkhi Rd., Bang Talat, Pak Kret, Nonthaburi 11120

Email: zhou.jirawat@gmail.com

Telephone: 084-360-1168

Privacy policy

We respect your privacy and are committed to protecting it through our compliance with this privacy policy (“Policy”). This Policy describes the types of information we may collect from you or that you may provide (“Personal Information”) on the กรอบรูปดอทคอม website (“Website” or “Service”) and any of its related products and services (collectively, “Services”), and our practices for collecting, using, maintaining, protecting, and disclosing that Personal Information. It also describes the choices available to you regarding our use of your Personal Information and how you can access and update it.

This Policy is a legally binding agreement between you (“User”, “you” or “your”) and frameindex.co.,ltd (“frameindex.co.,ltd”, “we”, “us” or “our”). If you are entering into this agreement on behalf of a business or other legal entity, you represent that you have the authority to bind such entity to this agreement, in which case the terms “User”, “you” or “your” shall refer to such entity. If you do not have such authority, or if you do not agree with the terms of this agreement, you must not accept this agreement and may not access and use the Website and Services. By accessing and using the Website and Services, you acknowledge that you have read, understood, and agree to be bound by the terms of this Policy. This Policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage.

Automatic collection of information

When you open the Website, our servers automatically record information that your browser sends. This data may include information such as your device’s IP address, browser type, and version, operating system type and version, language preferences or the webpage you were visiting before you came to the Website and Services, pages of the Website and Services that you visit, the time spent on those pages, information you search for on the Website, access times and dates, and other statistics.

Information collected automatically is used only to identify potential cases of abuse and establish statistical information regarding the usage and traffic of the Website and Services. This statistical information is not otherwise aggregated in such a way that would identify any particular User of the system.

Collection of personal information

You can access and use the Website and Services without telling us who you are or revealing any information by which someone could identify you as a specific, identifiable individual. If, however, you wish to use some of the features offered on the Website, you may be asked to provide certain Personal Information (for example, your name and e-mail address).

We receive and store any information you knowingly provide to us when you create an account, publish content, make a purchase, or fill any online forms on the Website. When required, this information may include the following:

• Account details (such as user name, unique user ID, password, etc)
• Contact information (such as email address, phone number, etc)
• Basic personal information (such as name, country of residence, etc)
• Payment information (such as credit card details, bank details, etc)
• Geolocation data of your device (such as latitude and longitude)
• Any other materials you willingly submit to us (such as articles, images, feedback, etc)

Some of the information we collect is directly from you via the Website and Services. However, we may also collect Personal Information about you from other sources such as public databases and our joint marketing partners.

You can choose not to provide us with your Personal Information, but then you may not be able to take advantage of some of the features on the Website. Users who are uncertain about what information is mandatory are welcome to contact us.

Privacy of children

We do not knowingly collect any Personal Information from children under the age of 18. If you are under the age of 18, please do not submit any Personal Information through the Website and Services. If you have reason to believe that a child under the age of 18 has provided Personal Information to us through the Website and Services, please contact us to request that we delete that child’s Personal Information from our Services.

We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Policy by instructing their children never to provide Personal Information through the Website and Services without their permission. We also ask that all parents and legal guardians overseeing the care of children take the necessary precautions to ensure that their children are instructed to never give out Personal Information when online without their permission.

Use and processing of collected information

We act as a data controller and a data processor when handling Personal Information, unless we have entered into a data processing agreement with you in which case you would be the data controller and we would be the data processor.

Our role may also differ depending on the specific situation involving Personal Information. We act in the capacity of a data controller when we ask you to submit your Personal Information that is necessary to ensure your access and use of the Website and Services. In such instances, we are a data controller because we determine the purposes and means of the processing of Personal Information.

We act in the capacity of a data processor in situations when you submit Personal Information through the Website and Services. We do not own, control, or make decisions about the submitted Personal Information, and such Personal Information is processed only in accordance with your instructions. In such instances, the User providing Personal Information acts as a data controller.

In order to make the Website and Services available to you, or to meet a legal obligation, we may need to collect and use certain Personal Information. If you do not provide the information that we request, we may not be able to provide you with the requested products or services. Any of the information we collect from you may be used for the following purposes:

• Create and manage user accounts
• Fulfill and manage orders
• Deliver products or services
• Improve products and services
• Send administrative information
• Send marketing and promotional communications
• Send product and service updates
• Respond to inquiries and offer support
• Request user feedback
• Improve user experience
• Enforce terms and conditions and policies
• Protect from abuse and malicious users
• Run and operate the Website and Services

Processing your Personal Information depends on how you interact with the Website and Services, where you are located in the world and if one of the following applies: (i) you have given your consent for one or more specific purposes; (ii) provision of information is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof; (iii) processing is necessary for compliance with a legal obligation to which you are subject; (iv) processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in us; (v) processing is necessary for the purposes of the legitimate interests pursued by us or by a third party.

Note that under some legislations we may be allowed to process information until you object to such processing by opting out, without having to rely on consent or any other of the legal bases. In any case, we will be happy to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Information is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Payment processing

In case of Services requiring payment, you may need to provide your credit card details or other payment account information, which will be used solely for processing payments. We use third-party payment processors (“Payment Processors”) to assist us in processing your payment information securely.

Payment Processors adhere to the latest security standards as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. Sensitive and private data exchange happens over a SSL secured communication channel and is encrypted and protected with digital signatures, and the Website and Services are also in compliance with strict vulnerability standards in order to create as secure of an environment as possible for Users. We will share payment data with the Payment Processors only to the extent necessary for the purposes of processing your payments, refunding such payments, and dealing with complaints and queries related to such payments and refunds.

Please note that the Payment Processors may collect some Personal Information from you, which allows them to process your payments (e.g., your email address, address, credit card details, and bank account number) and handle all the steps in the payment process through their systems, including data collection and data processing. Where necessary for processing future or recurring payments and subject to your prior consent, your financial information will be stored in encrypted form on secure servers of our Payment Processors. The Payment Processors’ use of your Personal Information is governed by their respective privacy policies which may or may not contain privacy protections as protective as this Policy. We suggest that you review their respective privacy policies.

We may also ask you to permit us to collect data about you from third-party providers to verify your identity, do a credit check and prevent fraud or assess risk. This helps us ensure that you are using our Services legally, that you are eligible for the Services you want to use, and to protect your data and our Services from fraudsters who may put you and your money at risk.

Managing information

You are able to delete certain Personal Information we have about you. The Personal Information you can delete may change as the Website and Services change. When you delete Personal Information, however, we may maintain a copy of the unrevised Personal Information in our records for the duration necessary to comply with our obligations to our affiliates and partners, and for the purposes described below.

Disclosure of information

Depending on the requested Services or as necessary to complete any transaction or provide any Service you have requested, we may share your information with our trusted subsidiaries and joint venture partners, affiliates, contracted companies, and service providers (collectively, “Service Providers”) we rely upon to assist in the operation of the Website and Services available to you and whose privacy policies are consistent with ours or who agree to abide by our policies with respect to Personal Information. We will not share any information with unaffiliated third parties.

Service Providers are not authorized to use or disclose your information except as necessary to perform services on our behalf or comply with legal requirements. Service Providers are given the information they need only in order to perform their designated functions, and we do not authorize them to use or disclose any of the provided information for their own marketing or other purposes. We will share and disclose your information only with the following categories of Service Providers:

• Cloud computing services
• Communication and collaboration services
• Product engineering and design services
• Sales and marketing services
• User authentication services
• Website hosting service providers

We may also disclose any Personal Information we collect, use or receive if required or permitted by law, such as to comply with a subpoena or similar legal process, and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

In the event we go through a business transition, such as a merger or acquisition by another company, or sale of all or a portion of its assets, your user account, and your Personal Information will likely be among the assets transferred.

Retention of information

We will retain and use your Personal Information for the period necessary as long as your user account remains active, to enforce our agreements, resolve disputes, and unless a longer retention period is required or permitted by law up to a maximum of 6 months.

We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally. Once the retention period expires, Personal Information shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification, and the right to data portability cannot be enforced after the expiration of the retention period.

Data analytics

Our Website and Services may use third-party analytics tools that use cookies, web beacons, or other similar information-gathering technologies to collect standard internet activity and usage information. The information gathered is used to compile statistical reports on User activity such as how often Users visit our Website and Services, what pages they visit and for how long, etc. We use the information obtained from these analytics tools to monitor the performance and improve our Website and Services. We do not use third-party analytics tools to track or to collect any personally identifiable information of our Users and we will not associate any information gathered from the statistical reports with any individual User.

Advertisements

We may permit certain third-party companies to help us tailor advertising that we think may be of interest to Users and to collect and use other data about User activities on the Website. These companies may deliver ads that might place cookies and otherwise track User behavior.

Social media features

Our Website and Services may include social media features, such as the Facebook and Twitter buttons, Share This buttons, etc (collectively, “Social Media Features”). These Social Media Features may collect your IP address, what page you are visiting on our Website and Services, and may set a cookie to enable Social Media Features to function properly. Social Media Features are hosted either by their respective providers or directly on our Website and Services. Your interactions with these Social Media Features are governed by the privacy policy of their respective providers.

Email marketing

We offer electronic newsletters to which you may voluntarily subscribe at any time. We are committed to keeping your e-mail address confidential and will not disclose your email address to any third parties except as allowed in the information use and processing section or for the purposes of utilizing a third-party provider to send such emails. We will maintain the information sent via e-mail in accordance with applicable laws and regulations.

In compliance with the CAN-SPAM Act, all e-mails sent from us will clearly state who the e-mail is from and provide clear information on how to contact the sender. You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails or by contacting us. However, you will continue to receive essential transactional emails.

Links to other resources

The Website and Services contain links to other resources that are not owned or controlled by us. Please be aware that we are not responsible for the privacy practices of such other resources or third parties. We encourage you to be aware when you leave the Website and Services and to read the privacy statements of each and every resource that may collect Personal Information.

Information security

We secure information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use, or disclosure. We maintain reasonable administrative, technical, and physical safeguards in an effort to protect against unauthorized access, use, modification, and disclosure of Personal Information in our control and custody. However, no data transmission over the Internet or wireless network can be guaranteed.

Therefore, while we strive to protect your Personal Information, you acknowledge that (i) there are security and privacy limitations of the Internet which are beyond our control; (ii) the security, integrity, and privacy of any and all information and data exchanged between you and the Website and Services cannot be guaranteed; and (iii) any such information and data may be viewed or tampered with in transit by a third party, despite best efforts.

As the security of Personal Information depends in part on the security of the device you use to communicate with us and the security you use to protect your credentials, please take appropriate measures to protect this information.

Data breach

In the event we become aware that the security of the Website and Services has been compromised or Users’ Personal Information has been disclosed to unrelated third parties as a result of external activity, including, but not limited to, security attacks or fraud, we reserve the right to take reasonably appropriate measures, including, but not limited to, investigation and reporting, as well as notification to and cooperation with law enforcement authorities. In the event of a data breach, we will make reasonable efforts to notify affected individuals if we believe that there is a reasonable risk of harm to the User as a result of the breach or if notice is otherwise required by law. When we do, we will post a notice on the Website, send you an email.

Changes and amendments

We reserve the right to modify this Policy or its terms related to the Website and Services at any time at our discretion. When we do, we will revise the updated date at the bottom of this page. We may also provide notice to you in other ways at our discretion, such as through the contact information you have provided.

An updated version of this Policy will be effective immediately upon the posting of the revised Policy unless otherwise specified. Your continued use of the Website and Services after the effective date of the revised Policy (or such other act specified at that time) will constitute your consent to those changes. However, we will not, without your consent, use your Personal Information in a manner materially different than what was stated at the time your Personal Information was collected.

Acceptance of this policy

You acknowledge that you have read this Policy and agree to all its terms and conditions. By accessing and using the Website and Services and submitting your information you agree to be bound by this Policy. If you do not agree to abide by the terms of this Policy, you are not authorized to access or use the Website and Services.

Contacting us

If you have any questions, concerns, or complaints regarding this Policy, the information we hold about you, or if you wish to exercise your rights, we encourage you to contact us using the details below:

sales@frameindex.com

We will attempt to resolve complaints and disputes and make every reasonable effort to honor your wish to exercise your rights as quickly as possible and in any event, within the timescales provided by applicable data protection laws.